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“A voidable judgment is one in which the court has jurisdiction over the subject matter and parties but which is otherwise erroneous and subject to reversal.” ¶ 16 (App. 1998) ().

(“Void judgments are those rendered by a court which lacked jurisdiction, either of the subject matter or the parties.”); see also Espinosa, 559 U.S. at 271 (“Rule 60(b)(4) applies only in the rare instance where a judgment is premised either on a certain type of jurisdictional error or on a violation of d

But “a complaint need not be technically sufficient to support a default judgment.” ¶ 19 (App. 2010) ( BRITT v. ADVANCED BUSINESS, et al. Decision of the Court 234 (1980)).

“To support a default judgment, a complaint need not be technically sufficient, but must contain a plain and concise statement of the cause of action[s] and give defendants fair notice of the allegations as a whole.” (emphasis added).

¶ 19 (App. 2010) (); see also Master Fin., ¶ 19 (App. 2004) (“A judgment or order is void if the court lacked jurisdiction over the subject matter, over the person, or over the particular judgment or order entered.”).

for Boys, (explaining that a default hearing is subject to the limitation of Rule 54(d) in that a court cannot award relief that “is more than or different in kind from that requested”); (recognizing that due process considerations may negate a court’s jurisdiction); see also United Student Aid Funds, Inc. v. Espinosa, 559 U.S. 260, 271 (2010) (construing Federal Rule of 2 Effective January 1, 2017, Rule 60(c) was re-numbered as Rule 60(b) but there are no substantive differences.

“It is important to remember that, at least with respect to jurisdiction, ‘void’ is not synonymous with ‘wrong’ or ‘erroneous.’”

Asphalt & Grading Co. v. CMX, LLC, ¶ 11 (2011) (acknowledging that “void judgments are those rendered by a court lacking jurisdiction over subject matter or parties” ()); see also Brumfield v. La.

( Tube City, 16 Ariz. at 311; and then Milliken v. Meyer, 311 U.S. 457, 462 (1940)).

(“Void judgments are those rendered by a court which lacked jurisdiction, either of the subject matter or the parties.”); Ezell, 224 Ariz. at 537, ¶¶ 18–19 (an erroneous judgment is not necessarily void and “only errors that undermine jurisdiction render a judgment void under Rule 60(c)(4)”).

(explaining judgments rendered by court lacking subject matter jurisdiction are void).

(holding that the failure to file an affidavit of service under Arizona Rule of Civil Procedure 4.2(b) (formerly Rule 4.2(e)(2)(b)), “although reversible error, did not render the default judgment void for lack of personal jurisdiction where the facts to be contained in that affidavit a

(explaining that void judgments are those rendered by a court lacking jurisdiction over subject matter or parties whereas erroneous judgments are those issued by courts with jurisdiction, but subject to reversal on appeal).

“Void judgments are those rendered by a court which lacked jurisdiction, either of the subject matter or the parties.” -35, -43 (1980).

240, 245 , (quoting Restatement of Judgments § 8(c) (1942)); , (adopting the Tamcff test to determine whether a default judgment based on a technically deficient complaint is void).

(“Confusion between void and merely erroneous judgments may stem from courts’ often loose usage of the word ‘void.’”).

(“Confusion between void and merely erroneous judgments may stem from courts’ often loose usage of the word ‘void.’ ”).